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- Improper use of data – not research based evidence
- Working Against Equity in Education - Another important argumen t
- Unworkability of Proposed System
- Mary Ann McKinnon
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Docket ID ED-2014-OPE-0057 The Honorable Arne Duncan Secretary U.S. Department of Education
On behalf of the executive board of the Massachusetts Chapter of the American Association of Colleges for Teacher Education (MACTE), we are responding to the U.S. Department of Education’s proposed regulations for teacher preparation programs released in the Notice of Proposed Rule Making (NPRM) on December 3, 2014. Massachusetts has a strong history of achievement among our students. As we transition to the use of the Curriculum Frameworks with the Common Core embedded in those Frameworks, continue our Rethinking Equity in the Teaching of English Language Learners (RETELL) and the implementation of a new educator evaluation system, it is even more critical that our educator preparation programs for teachers and leaders prepare educators who are ready to hit the ground running when they enter classrooms. Educator preparation programs in Massachusetts, in collaboration with the MA Department of Elementary and Secondary Education and the MA Department of Higher Education, have been deeply involved in the work of measuring educator alumnae performance and improving teacher preparation programs through the Council of Chief State School Officer’s (CCSSO) Network for the Transformation of Educator Preparation (NTEP). Massachusetts was one of seven states chosen by CCSSO to participate in this two-year project to transform educator preparation and entry systems into the profession. The work of preparing our future educators is essential to the strong system of elementary and secondary education Massachusetts provides our young citizens. Through our NTEP work, we have already employed accountability mechanisms such as these in Massachusetts: Availability, review and use of MA program completer employment and retention data to inform continuous improvement of educator preparation programs through Edwin Analytics Development of a new preservice teacher performance assessment Alignment of preservice standards with new MA educator evaluation standards/rubrics Overhaul of EPP review and approval protocol and metrics New data collection and analysis initiatives and protocol Specific NTEP project initiatives include: Licensure: Build a performance-based licensure system that includes standards and indicators that are assessed and aligned with educator evaluation. • Build a new Teacher Performance Assessment • Revise and implement the Professional Standards and Indicators for Teachers for preparation and licensure to align with teacher evaluation • Design a re-envisioned licensure system Program Approval: Build an educator preparation program review system that: 1) is based on evidence, 2) allows for differentiation based on program effectiveness and 3) supports continuous improvement and enhancement through the use of data. • Develop and provide training on data use to inform programs, faculty and teacher candidates • Build and implement an evidentiary-based program review system
• Map license to the work assignment in the district • Participate in the CCSSO/NTEP initiative for national educator data sharing • Create an Educator Licensing and Recruitment (ELAR) System User Guide Our teacher preparation programs also undergo continual reform influenced by the latest research about effective practice, feedback from our K-12 partners, local and national workforce demands, new requirements from our legislature and state, new professional standards for preparation, and funding to support new initiatives. Our teacher preparation programs actively support accountability mechanisms that are fair, transparent, valid, reliable, feasible, and useful for program improvement. Overall, if these proposed regulations were adopted, they would draw energy, funding, and attention away from innovative reforms, proven accountability initiatives, and overall program improvement currently under way in teacher preparation programs across the country. Improper use of data – not research based evidence Currently, no state fully implements the performance rating system proposed by the regulations for teacher preparation programs. Evidence is lacking that the indicators prescribed by this regulation actually represent program effectiveness. While teacher preparation programs routinely seek much of this information for feedback and program improvement, any algorithm based on these data elements would be unlikely to generate a rating number that would accurately or substantively reflect program effectiveness. We are also concerned about the absence of guarantees of data quality. At the heart of this proposal is the collection and utilization of massive amounts of data from both K-12 and higher education. Ensuring that the data are valid and reliable is of paramount importance and a laborious task that takes ongoing resources not readily available in institutions or states. The Department indicates that one of the goals of this proposal is to provide prospective teachers and employers as well as policy makers with accurate data for informed decision making. The proposed regulations would not meet that goal. Rather, stakeholders would be left with ratings that are not comparable comprised of indicators that, as a whole, have not be proven to represent program quality. The result will be misinformed high-stakes decision making. Working Against Equity in Education - Another important argument The Elementary and Secondary Education Act (ESEA) requires that states work to change the disproportionate congregation of inexperienced teachers in high-need schools (PL 107- 110, Section 1111(b)(8)(C)). Yet these proposed regulations would promote that very practice by incentivizing preparation programs to place first-year teachers in high-need schools (NPRM, p. 71286). The regulations themselves have internal cross purposes. On the one hand, they incentivize programs to place graduates in better performing schools (typically not high-need schools) through the mandate that student learning outcomes be given the most weight among the indicators required to create a program rating. On the other hand, the proposed regulations incentivize the placement of graduates in high-need schools, as the employment rates in high-need schools would receive the next highest weight when calculating a program rating. This counteraction leads to not only confusion, but overall challenges in how the regulations could be implemented, and with high-stakes consequences for such ratings at hand. New teachers, especially those in high-need schools, need strong, sustained induction to remain not only in the school but in the profession overall. Without funding to build and maintain induction programs, new teachers too often leave the high-need school and the profession, and the cycle of new teachers serving in schools where students most need experienced educators continues. These regulations would add to the problem of congregating the least experienced teachers in high-need schools. Unworkability of Proposed System Educator preparation programs in Massachusetts support the Department’s proposed rules requiring reporting of provider outcome measures. Our concern lies with the ability to meaningfully designate performance ratings of exceptional, effective, at-risk or low-performing by program annually. The primary challenge lies in the make-up of Massachusetts providers. Massachusetts has 71 entities approved to offer Initial teacher licenses. In 2012-13, there were 787 individual programs leading to an Initial teacher license for which there was at least 1 completer (considered active programs). Of these active programs, only 11 (or 0.014%) met the proposed threshold level of 25 employed new teachers for the 2013-2014 academic year. If the state were to select to drop the threshold to 15 new teachers, which is discouraged in the proposed regulations for validity and reliability concerns, there are 24 additional programs that could be reported on, making for a total of 35 of 787 discrete programs. However, even with the different options to accommodate low-enrollment programs, there are 20 entities in Massachusetts for whom even if we aggregate all programs and aggregate for three years of data, we will still not meet the 25 new teacher threshold. Consequently, most of the data reported will be for completers of public higher education teacher preparation programs. From Jo-Ann - Could you boost your argument by adding a little more to this statement about the mission of the public IHEs which I think is of great value. Maybe: Therefore, the regulations will have a disproportionate impact on programs serving large numbers of candidates from underrepresented groups, including students of color and first generation students. MA public IHEs are proud to carry forward the stated mission of the Board of Higher Education which is “to ensure that Massachusetts residents have the opportunity to benefit from a higher education that enriches their lives and advances their contributions to the civic life, economic development, and social progress of the Commonwealth. To that end, the programs and services of Massachusetts higher education must meet standards of quality commensurate with the benefits it promises and must be truly accessible to the people of the Commonwealth in all their diversity.” Because of this as a group, they have a greater need of federal financial aid, may themselves have been schooled in high-poverty districts, may need additional time and resources to complete teacher preparation programs, and may be limited geographically in their program choice. Therefore, the regulations will have a disproportionate impact on programs serving large numbers of candidates from underrepresented groups, including students of color and first generation students. As a group, they have a greater need of federal financial aid, may themselves have been schooled in high-poverty districts, may need additional time and resources to complete teacher preparation programs, and may be limited geographically in their program choice. In addition, the aggregation of the programs in order to meet the threshold will require a significant amount of manual calculation on an annual basis. Given the heightened accountability around the reporting, the state will be required to use human judgment to make common-sense groupings and aggregations in order to meet the necessary threshold. Conclusion The Commonwealth of Massachusetts has invested heavily over the last three years to implement similar reforms. Our Department of Elementary and Secondary Education is staffed and resourced to continue on a trajectory that we believe will allow us to achieve the same goals as those outlined in the proposed rules. Having to alter our current course to meet the full scope and nuanced differences in these rules will cost more than the benefit we would have gained in Massachusetts. We appreciate the Department’s efforts in the development of these proposed rules and are grateful for the opportunity to provide public comment. As the MACTE president, I would be pleased to respond to any questions that you or your staff may have or to provide any additional information regarding this response to the proposed regulations on teacher preparation programs. I can be reached at 508 531-1347 or via e-mail at mmckinnon@bridgew.edu. Sincerely, Mary Ann McKinnon, President, MA Association of Colleges for Teacher Education Associate Dean, Bridgewater State University 2014-2016 MACTE Executive Board: Lorne Ranstrom President-Elect Eastern Nazarene College Marge Magouirk Colbert Secretary University of MA at Amherst Donna E. McKibbens Treasurer Wheelock College Kathleen McNamara Past-President Stonehill College Janet S. Arndt Gordon College Bev Bell Mt. 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